ND-19-0064, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.6.05.02.ii (Index Number 629)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.6.05.02.ii (Index Number 629)

ML19031B390
Person / Time
Site:	Vogtle
Issue date:	01/31/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0064
Download: ML19031B390 (9)

Text

~ Southern Nuclear Michael J. Yox Regulatory Affairs Director 7825 River Road Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 tel 410-4 74-8587 cell JAN 3 1 2019 myox@southernco.com Docket Nos.: 52-025 52-026 ND-19-0064 10 CFR 52 .99(c)(3)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 and Unit 4 Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item 2.6.05.02.ii [Index Number 6291 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of January 31 , 2019, Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Uncompleted Inspections Tests Analyses and Acceptance Criteria (ITAAC) Item 2.6.05.02.ii

[Index Number 6291 has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing ITAAC 2.6.05.02.ii [Index Number 629}. Southern Nuclear Operating Company will, at a later date, provide additional notifications for ITAAC that have not been completed 225-days prior to initial fuel load .

This notification is informed by the guidance described in NEl-08-01 , Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52, which was endorsed by the NRC in Regulatory Guide 1.215. In accordance with NEI 08-01 , this notification includes ITAAC for which required inspections, tests, or analyses have not been performed or have been only partially completed .

All ITAAC will be fully completed and all Section 52.99(c)(3) ITAAC Closure Notifications will be submitted to NRC to support the Commission finding that all acceptance criteria are met prior to plant operation, as required by 10 CFR 52.103(g).

This letter contains no new NRC regulatory commitments.

If there are any questions, please contact Tom Petrak at 706-848-1575.

U.S. Nuclear Regulatory Commission ND-19-0064 Page2of 4 Respectfully submitted,

?!/~ ~

Michael J. Yox Regulatory Affairs irector Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.6.05.02.ii [Index Number 629]

MJY/DJG/sfr

U.S. Nuclear Regulatory Commission ND-19-0064 Page3of 4 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. D. A. Bost (w/o enclosures)

Mr. D. L. McKinney (w/o enclosures)

Mr. M. D. Meier (w/o enclosures)

Mr. D. H. Jones (w/o enclosures)

Mr. J.B. Klecha Mr. G. Chick Mr. M. J. Yox Mr. A. S. Parton Ms. K. A. Roberts Mr. T. G. Petrak Mr. W. A. Sparkman Mr. C. T. Defnall Mr. C. E. Morrow Mr. J. L. Hughes Ms. K. M. Stacy Ms. A. C. Chamberlain Mr. J.C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures)

Mr. F. D. Brown Ms. J. M. Heisserer Mr. C. P. Patel Mr. G. J. Khouri Ms. S. E. Temple Mr. N. D. Karlovich Mr. A. Lerch Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. I. Cozens Mr. J. Gaslevic Mr. V. Hall Oglethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-19-0064 Page4 of 4 Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Dr. L. Oriani (w/o enclosures)

Mr. D. C. Durham (w/o enclosures)

Mr. M. M. Corletti Ms. L. G. Iller Ms. J. Monahan Mr. J. L. Coward Other Mr. J. E. Hesler, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.

Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kemizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham

U.S. Nuclear Regulatory Commission ND-19-0064 Enclosure Page 1 of 5 Southern Nuclear Operating Company ND-19-0064 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.6.05.02.ii [Index Number 629]

U.S. Nuclear Regulatory Commission ND-19-0064 Enclosure Page2of 5 ITAAC Statement Design Commitment

2. The ELS has six groups of emergency lighting fixtures located in the MCR and at the RSW.

Each group is powered by one of the Class 1E inverters. The ELS has four groups of panel lighting fixtures located on or near safety panels in the MCR. Each group is powered by one of the Class 1E inverters in Divisions Band C (one 24-hour and one 72-hour inverter in each Division).

5. The normal lighting can provide 50 foot candles at the safety panel and at the workstations in the MCR and at the RSW.

6. The emergency lighting can provide 1Ofoot candles at the safety panel and at the workstations in the MCR and at the RSW.

lnspections/Tests/Analyses i) Inspection of the as-built system will be performed.

ii) Testing of the as-built system will be performed using one Class 1E inverter at a time.

i) Testing of the as-built normal lighting in the MCR will be performed.

ii) Testing of the as-built normal lighting at the RSW will be performed.

i) Testing of the as-built emergency lighting in the MCR will be performed.

ii) Testing of the as-built emergency lighting at the RSW will be performed.

Acceptance Criteria i) The as-built ELS has six groups of emergency lighting fixtures located in the MCR and at the RSW. The ELS has four groups of panel lighting fixtures located on or near safety panels in the MCR.

ii) Each of the six as-built emergency lighting groups is supplied power from its respective Class 1E inverter and each of the four as-built panel lighting groups is supplied power from its respective Class 1E inverter.

i) When adjusted for maximum illumination and powered by the main ac power system, the normal lighting in the MCR provides at least 50 foot candles at the safety panel and at the workstations.

ii) When adjusted for maximum illumination and powered by the main ac power system, the normal lighting in the RSW provides at least 50 foot candles at the safety panel and at the workstations.

U.S. Nuclear Regulatory Commission N D-19-0064 Enclosure Page3of 5 i) When adjusted for maximum illumination and powered by the six Class 1E inverters, the emergency lighting in the MGR provides at least 1O foot candles at the safety panel and at the workstations.

ii) When adjusted for maximum illumination and powered by the six Class 1E inverters, the emergency lighting provides at least 10 foot candles at the RSW.

ITAAC Completion Description Multiple ITAAC are performed to demonstrate the Lighting System (ELS) has six groups of emergency lighting fixtures located in the Main Control Room (MGR) and at the Remote Shutdown Workstation (RSW) with each group being powered by one of the Class 1E inverters, the ELS has four groups of panel lighting fixtures located on or near safety panels in the MGR with each group being powered by one of the Class 1E inverters in Divisions Band C (one 24-hour and one 72-hour inverter in each Division), the normal lighting can provide 50 foot candles at the safety panel and at the workstations in the MGR and at the RSW, and the emergency lighting can provide 1O foot candles at the satety panel and at the workstations in the MGR and at the RSW. The subject ITAAC requires inspections of the as-built ELS, testing of the as-built ELS using one Class 1E inverter at a time, testing of the as-built normal lighting in the MGR and RSW, and testing of the as-built emergency lighting in the MGR and RSW.

i) The as-built ELS has six groups of emergency lighting fixtures located in the MGR and at the RSW. The ELS has four groups of panel lighting fixtures located on or near safety panels in the MGR.

The ELS in the MGR and RSW is inspected in accordance with ND-RA-001-012 (Reference 1).

The results of the inspection are included in the Unit 3 and Unit 4 ITAAC Technical Reports SV3-ELS-ITR-800629 and SV4-ELS-ITR-800629 (References 2 and 3) and confirm that the as-built ELS has six groups of emergency lighting fixtures located in the MGR and at the RSW and the ELS has four groups of panel lighting fixtures located on or near safety panels in the MGR.

ii) Each of the six as-built emergency lighting groups is supplied power from its respective Class 1E inverter and each of the four as-built panel lighting groups is supplied power from its respective Class 1E inverter.

The six groups of emergency lighting fixtures located in the MGR and at the RSW, and the four groups of panel lighting fixtures located on or near the safety panels in the MGR, are tested in accordance with Unit 3 and Unit 4 preoperational test procedures, 3-ELS-ITPP-501, 4-ELS-ITPP-501, 3-IDS-ITPP-501, and 4-IDS-ITPP-501 (References 4 through 7). These fixtures are supplied power from their respective Class 1E inverter through the respective Class 1E distribution panel.

Testing to verify that each of the six as-built emergency lighting groups is supplied power from its respective Class 1E inverter and each of the four as-built panel lighting groups is supplied power from its respective Class 1E inverter is performed in two parts. Testing in 3/4-IDS-ITPP-501 verifies that the respective Class 1E inverter supplies power to the respective distribution panel through a load bank test. Testing in 3/4-ELS-ITPP-501 verifies that the respective

U.S. Nuclear Regulatory Commission ND-19-0064 Enclosure Page4 of 5 distribution panel supplies power to each group of emergency and panel lighting fixtures by de-energizing and re-energizing the group from the lighting panel breaker in the distribution panel and verifying that each lighting fixture in the respective group turns off and on.

The test results are included in References 4 through 7 and confirm that each of the six as-built emergency lighting groups is supplied power from its respective Class 1E inverter and each of the four as-built panel lighting groups is supplied power from its respective Class 1E inverter.

i) When adjusted for maximum illumination and powered by the main ac power system. the normal lighting in the MCR provides at least 50 foot candles at the safety panel and at the workstations.

The illumination levels of the normal lighting in the MCR are measured in accordance with Unit 3 and Unit 4 preoperational test procedures 3-ELS-ITPP-501 and 4-ELS-ITPP-501 (References 4 and 5). The testing is performed with all lighting fixtures powered from the main ac power source, the dimmer control set for maximum illumination, all large screen displays off, and all lighting in adjacent rooms with windows to the MCR off. The illumination levels at the safety panel and the workstations are measured with a light meter. The test results are included in References 4 and 5 and confirm that when adjusted for maximum illumination and powered by the main ac power system, the normal lighting in the MCR provides at least 50 foot candles at the safety panel and at the workstations.

ii) When adjusted for maximum illumination and powered by the main ac power system, the normal lighting in the RSW provides at least 50 foot candles at the safety panel and at the workstations.

The illumination levels of the normal lighting in the RSW are measured in accordance with Unit 3 and Unit 4 preoperational test procedures 3-ELS-ITPP-501 and 4-ELS-ITPP-501 (References 4 and 5). The testing is performed with all lighting fixtures powered from the main ac power source with the dimmer control set for maximum illumination. The illumination levels at the safety panel and the workstations are measured with a light meter. The test results are included in References 4 and 5 and confirm that when adjusted for maximum illumination and powered by the main ac power system, the normal lighting in the RSW provides at least 50 foot candles at the safety panel and at the workstations.

i) When adjusted for maximum illumination and powered by the six Class 1E inverters, the emergency lighting in the MCR provides at least 1o foot candles at the safety panel and at the workstations.

The illumination levels of the emergency lighting in the MCR are measured in accordance with Unit 3 and Unit 4 preoperational test procedures 3-ELS-ITPP-501 and 4-ELS-ITPP-501 (References 4 and 5). Testing is performed with the normal power isolated at the main breaker of each lighting panel, all lighting fixtures powered from the Class 1E inverters, the dimmer control set for maximum illumination, all large screen displays off, and all lighting in adjacent rooms with windows to the MCR off. The illumination levels at the satety panel and the workstations are measured with a light meter. The test results are included in References 4 and 5 and confirm that when adjusted for maximum illumination and powered by the six Class 1E

U.S. Nuclear Regulatory Commission ND-19-0064 Enclosure Pages of 5 inverters, the emergency lighting in the MCA provides 1O foot candles at the safety panel and at the workstations.

ii) When adjusted for maximum illumination and powered by the six Class 1E inverters, the emergency lighting provides at least 1O foot candles at the RSW.

The illumination levels of the emergency lighting in the MCA and at the RSW are measured in accordance with Unit 3 and Unit 4 preoperational test procedures 3-ELS-ITPP-501 and 4-ELS-ITPP-501 (References 4 and 5). Testing is performed with the normal power isolated at the main breaker of each lighting panel, all lighting fixtures powered from the Class 1E inverters, and the dimmer control set for maximum illumination. The illumination levels at the safety panel and the workstations are measured with a light meter. The test results are included in References 4 and 5 and confirm that when adjusted for maximum illumination and powered by the six Class 1E inverters, the emergency lighting can provide 1O foot candles at the RSW.

References 2 through 7 are available for NRC inspection as part of Unit 3 and Unit 4 ITAAC Completion Packages (References 8 and 9).

List of ITAAC Findings In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company (SNC) performed a review of all findings pertaining to the subject ITAAC and associated corrective actions. This review found there are no relevant ITAAC findings associated with this ITAAC.

References (available for NRC inspection)

1. ND-RA-001-012, "Functional Arrangement Scoping Process"

2. SV3-ELS-ITR-800629, "Unit 3 ITAAC Technical Report"

3. SV4-ELS-ITR-800629, "Unit 4 ITAAC Technical Report"

4. 3-ELS-ITPP-501, Unit 3 "Lighting System Preoperational Test

5. 4-ELS-ITPP-501, Unit 4 "Lighting System Preoperational Test

6. 3-IDS-ITPP-501, Unit 3 "Class 1E DC and UPS Preoperational Test

7. 4-IDS-ITPP-501, Unit 4 "Class 1E DC and UPS Preoperational Test"

8. 2.6.01.04d-U3-CP-Rev 0, ITAAC Completion Package

9. 2.6.01.04d-U4-CP-Rev 0, ITAAC Completion Package

10. NEI 08-01, "Industry Gu.ideline for the ITAAC Closure Process Under 10 CFR Part 52"